Key takeaways
- POS 10 is now required for home-based telehealth — using POS 11 causes denials
- Modifier 95 (video), FQ (audio-only), and GQ (asynchronous) must be used correctly
- Telehealth billing rules are based on patient location, not provider location
- 42 states have parity laws but with significant variations
- Commercial payer policies are diverging — review each contract individually
Telehealth has evolved from a pandemic necessity into a permanent fixture of modern healthcare delivery. However, the billing rules governing telehealth services continue to shift, creating compliance challenges for practices of all sizes. The 2026 landscape brings new modifier requirements, updated place of service codes, and significant payer-specific policy changes that every billing team must understand.
Place of Service Code Updates
CMS has finalized Place of Service (POS) code 10 for telehealth services provided to patients in their homes. This replaces the temporary COVID-era guidance that allowed POS 11 (office) for many telehealth encounters. Using the incorrect POS code is now a leading cause of telehealth claim denials.
For telehealth services where the patient is at a non-home originating site (such as a rural health clinic or hospital outpatient department), POS 02 remains the appropriate code. The distinction between POS 02 and POS 10 determines reimbursement rates, with POS 10 typically reimbursing at the facility rate.
Audio-only telehealth services have their own billing requirements. CMS now requires modifier 93 for audio-only encounters, and not all CPT codes are eligible for audio-only delivery. Practices must maintain an updated list of audio-only eligible services.
Modifier Requirements for 2026
Modifier 95 remains required for synchronous telehealth services using real-time audio and video. This modifier signals to the payer that the service was delivered via telehealth and drives correct claim adjudication.
The new modifier FQ has been introduced for telehealth services provided using audio-only technology when the patient lacks access to two-way audio/video technology. This modifier is accepted by Medicare and an increasing number of commercial payers.
Asynchronous (store-and-forward) telehealth services require modifier GQ. This applies primarily to dermatology, radiology, and pathology services where images or data are transmitted for later review by a specialist.
Practical tips
- Create a modifier decision tree for your coding team to reduce errors
- Verify payer-specific modifier requirements — not all payers follow CMS guidelines
- Audit telehealth claims monthly to catch modifier errors before they become trends
State-by-State Parity Laws
Telehealth parity laws — which require payers to reimburse telehealth at the same rate as in-person services — vary dramatically by state. As of 2026, 42 states have some form of telehealth parity law, but the specifics differ significantly.
Some states mandate payment parity only for certain service types or provider categories. Others include provisions that sunset in 2027, creating uncertainty for practices planning their telehealth strategy.
Multi-state practices face particular complexity, as the billing rules that apply depend on where the patient is located at the time of service, not where the provider is located. This means a single practice may need to follow different rules for different patient encounters.
Watch out for
- Always bill based on the patient's location, not the provider's location
- State parity laws may not apply to self-funded employer health plans (ERISA preemption)
- Some states require specific informed consent documentation for telehealth encounters
Commercial Payer Policies: Key Differences
UnitedHealthcare now requires prior authorization for certain high-frequency telehealth services, including behavioral health visits exceeding four per month. This is a significant departure from the open-access policies of the pandemic era.
Anthem/Elevance has implemented a telehealth platform requirement, mandating that providers use approved telehealth platforms to qualify for in-network reimbursement. Services delivered via non-approved platforms may be denied or reimbursed at reduced rates.
Aetna has expanded its telehealth-eligible service list to include chronic care management, remote patient monitoring setup, and certain preventive screenings. Practices should review their Aetna contracts for updated telehealth provisions.
About this article
Published by the DrCareMSO team. It is general information for practice owners and billing staff, not legal, coding or compliance advice. Coding rules and payer policies change, so check current CMS, AMA and payer guidance before you act.
